FAQ: Must the “Operator” of a satellite accumulation area be a single individual?

FAQ: Must the “Operator” of a satellite accumulation area be a single individual?

Background:

The satellite accumulation area (SAA) regulations of the US. Environmental Protection Agency (USEPA) at 40 CFR 262.15 mandate that the container of hazardous waste in the SAA be “under the control of the operator of the process generating the waste,…”

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Answer: (FR 81, no. 228, 11.28.16 85768)

USEPA believes that there can be more than one operator per SAA over time. For example, as employees change shifts over the course of a day, the role of the operator can be transferred from one employee to another.

Likewise, the Agency believes that there can also be more than one operator per SAA at the same time. For example, multiple operators may be running laboratory equipment in the same room and share hazardous waste containers located in a single SAA.

However, the term operator does refer to an individual or individuals responsible for the equipment or processes generating the hazardous waste and does not refer to a company or entity as a whole.